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If a similar decision were handed down in another state, it might attract unwanted business from the porn industry.

(Click here for an excellent review of this distinction by Sherry F.

Colb.) Free-speech advocates argue that this ought to hold true for "gonzo" films, in which the person behind the camera also joins in on the action; no significant cases have gone to court, however.

Performers may engage in sex as part of their roles—they presumably follow a script—but that doesn't count as sex for hire.

Sex in the course of creating a movie or a photo is just plain old expression, protected under the First Amendment.